I'm looking for guidance on assumptions to pruchase and calculating rate spread for the LAR. What does one use as the date the interest rate was set? For instances, if the interest rate was set on the loan being assumed 3 years ago, do we use that date?

Thanks --

I couldn't find anything "concrete" and we do not allow assumptions, therefore the following is only opinion.

I will assume you have a written agreement between you and the person assuming the loan, otherwise the transaction is not reportable. The person assuming the loan presented an application to do so, you approved the assumption and the rate was set for that person. IMO, you will use the date the final rate was set for the person assuming the loan. That rate could be the loan's current rate or a different rate but the rate was set sometime during the application process for the person assuming the loan.

Yes Dan, we do have an agreement with the new borrower and your response is logical, but HMDA rarely makes sense!! Thanks --